Engen Botswana Limited

On March 13, 2019, the Mississippi Department of Finance & Administration identified Engen Botswana as a company “engaged in investment activities in Iran, providing funds, goods or services valued at $20,000,000 or more in the energy sector of Iran. (https://www.dfa.ms.gov/media/8124/businesses-doing-business-with-iran.pdf)

As of May 28, 2020, the Florida State Board of Administration (“SBA”) continues to list Engen Botswana on its list of “Scrutinized companies with Activities in the Iran Petroleum Energy Sector.”  (https://www.sbafla.com/fsb/Portals/FSB/Content/GlobalGovernanceMandates/QuarterlyReports/2020/Global_Governance_Mandates_and_Florida Statutes_2020_05_28.pdf?ver=2020-05-28-122524-540)

In 2020, the U.S. state of Mississippi listed Engen Botswana on its state lists of Companies Doing Business with the Iranian Petroleum/Natural Gas, Nuclear and Military Sectors, rendering it ineligible for investment and/or state contracting. (https://www.dfa.ms.gov/media/sd1ccddh/businesses-doing-business-with-iran-12-4.docx)

On March 24, 2015, Engen Botswana was added to the Florida State Board of Administration List of Prohibited Investments (Scrutinized Companies) due to its involvement in Iran. As of March 9, 2021, Engen Botswana remains on the SBA list of prohibited investments.  (https://www.sbafla.com/fsb/Portals/FSB/Content/Performance/Quarterly/2021_03_09_Web_Update_PFIA_Prohibited_List.pdf?ver=2021-03-09-134849-587)

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Engen Botswana is listed on the June 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list. (http://treasury.dor.alaska.gov/Portals/3/docs/resolutions/ARMB%20Iran%20Divestment%20List%206-30-19.pdf)

Engen Botswana is listed on the June 4, 2019 and July 12, 2019 Florida State Board of Administration list of prohibited investments (Scrutinized companies) for Iran related business. (https://www.sbafla.com/fsb/Portals/FSB/Content/Performance/Quarterly/2019_06_04_Web_Update_PFIA_Prohibited_List.pdf?ver=2019-06-04-162911-617) (https://www.sbafla.com/fsb/Portals/FSB/Content/Performance/Quarterly/2019_07_12_Web_Update_PFIA_Prohibited_List.pdf?ver=2019-07-12-114201-343)

Engen Botswana is listed on the March 2019 Alaska Retirement Management Board, Companies Doing Material Business with Iran list. (http://treasury.dor.alaska.gov/Portals/3/docs/resolutions/ARMB%20Iran%20Divestment%20List%203-31-19.pdf)

As of December 31, 2019, the Alaska Retirement Management Board lists Engen Botswana as a company doing material business with Iran. (https://treasury.dor.alaska.gov/Portals/3/docs/resolutions/ARMB Iran Divestment List 12-31-19.pdf)

In 2015, 2016 and 2017 Engen Botswana was listsed on the Texas Pension Review Board List of Scrutinized Companies doing business in Iran pursuant to Chapter 807.054, Government Code.   (https://comptroller.texas.gov/purchasing/publications/divestment.php)

on January 13, 2020, the South Dakota Investment Council submitted a report to the Executive Board of the Legislative Research Council regarding compliance with SDCL 4-5-48 to 4-5-60, Iran Divestiture. Included in this report is an Iran Scrutinized Companies list of all prohibited investments for which the internal managers and direct external managers are instructed not to purchase any company on the list. Engen Botswana is included on this list. (https://sdlegislature.gov/docs/referencematerials/requiredreports/RR901152020.pdf)